Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires the Organization to establish and
maintain effective internal control over federal awards.
Condition: 14 out of 60 transactions sampled to test for allowable activities and cost principles did not have
documented internal controls over compliance.
Cause: There were no written procedures over allowable costs and when changes in management and
accounting services occurred internal control documentation was not consistent.
Effect or Potential Effect: Costs charged to the federal program may not be allowable.
Context: 60 out of 739 disbursement transactions were tested.
Repeat Finding: No
Recommendation: Internal controls over compliance for allowable activities and cost principles should be
documented and design and document procedures over allowable cost principles.
Views of Responsible Officials: Management agrees with the finding and will implement procedures to
document internal controls over compliance for allowable activities and cost principles.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.302(b)(6) requires the non-Federal entity to provide
written procedures to implement the requirements of cash management as defined in 200.305.
Condition: 2 out of 5 draw requests did not have documented approvals.
Cause: There were no written procedures over cash management and when changes in management and
accounting services occurred internal control documentation was not consistent. Effect or Potential Effect: Time elapsing between the transfer of funds and disbursements may not be
minimized.
Context: 5 out of 46 draw requests were tested. In addition, 4 significant draw requests were tested and all
of those had documented approvals for internal control over cash management.
Repeat Finding: This finding is a repeat of Finding 2022-004.
Recommendation: The Organization document internal control over compliance procedures and document
written procedures to ensure compliance with 2 CFR 200.305.
Views of Responsible Officials: Management agrees with the finding and will implement documentation of
internal controls and document its policies and procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with federal
statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.
Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System - September1, 2019 through August 31, 2024, September1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: Per the provisions of the grant agreements, key personnel changes are
to be communicated with the grantors. Condition: No communications were made for a change in the Executive Director position.
Cause: No written procedures to ensure that federal awards are reviewed to identify special award terms
and conditions and compliance with identified special award terms and conditions.
Effect or Potential Effect: The Organization may be in noncompliance with a special term and condition in
which the grantor may implement additional conditions, withhold payments, or suspend or terminate all or
a portion of the award.
Repeat Finding: No
Recommendation: Communication with grantors should be made per award terms for changes in key
personnel. Written procedures should ensure federal awards are reviewed for special terms and conditions
and that compliance with those terms and conditions are met.
Views of Responsible Officials: Management agrees with the finding and will implement special award terms
and conditions procedures.