2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-006 Activities Allowed and Allowable Costs (Significant Deficiency in Internal Controls over Compliance)
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number: Not Applicable
Award Year: 2024
Assistance Listing Number: 93.658
Questioned Costs: Not Applicable
Condition: Three out of fifteen applications for stipend payments tested did not have final approval.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Cause: The University did not have sufficient controls in place to review application to ensure final approval.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-004 Controls over Non-Payroll (Material Weakness in Internal Controls over Compliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1742599 & 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During non-payroll testing, CRI noted the following: • Out of 25 items tested in the R&D Cluster, 17 were not approved by the Grant Director or the Office of Research and Sponsored Projects.
• Out of 25 items tested in the Southwest Forest Health and Wildfire Prevention grant, 12 did not have an approved purchase requisition or pre-approval report.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per Title 2 US Code of Federal Regulations Part 200.403g, costs must be adequately documented to be allowable under Federal awards.
Cause: The University is not following procedures to ensure the appropriate approvals are being conducted on all purchases or retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-005 (2022-005) Procurement, Small Purchase (Significant Deficiency in Internal Controls over Compliance with Questioned Costs Greater than $25,000) - Repeated
Title: Research and Development Cluster
Funding Agency: National Science Foundation
Federal Award Agreement Number: 1914463, 1953487
Award Year: 2024
Assistance Listing Number: 47.076
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013
Award Year:2024
Assistance Listing Number:10.694
Condition: During our review of procurement testing in the Research and Development Cluster, the University did not follow small purchase procedures and did not have an annual self-certification election to follow micropurchase procurement for professional services. In our procurement testing in the Southwest Forest Health and Wildfire Prevention grant, no support was provided to test the procurement methods used for small purchases.
Progress on resolution of prior year finding: No progress was made.
Questioned Costs: Known and likely questioned costs of $78,063 and $30,975 in the R&D Cluster and the Southwest Forest Health and Wildfire Prevention program, respectively.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained and 2 CFR 200.320(a)(1)(iv) states the recipient may self-certify a threshold up to $50,000 on an annual basis and must maintain documentation to be made available to the auditors which includes a justification, clear identification of the threshold, and supporting documentation.
Per Title 2 US Code of Federal Regulations Part 200.403(g), costs must be adequately documented to be allowable under Federal awards.
Cause: The University was using a $50,000 threshold for professional services to utilize micropurchase method of procurement in the Research and Development Cluster. In the Southwest Forest Health and Wildfire Prevention grant, the University was not retaining the supporting documentation to ensure purchase is allowable.
Effect: The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. In addition, the University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency
2024-003 Controls over Payroll (Material Weakness in Internal Controls over Compliance and Material Noncompliance)
Title: Research and Development Cluster
Funding Agency, Federal Award, Agreement Number, Award Year, Assistance Listing Number:
National Science Foundation, 2122108, 2024,47.049
National Science Foundation, 1953487, 2024,47.076
United States Department of Education, P031C160248, 2024, 84.031C
United States Department of Health and Human Services, 1R16GM146669-01 & Q02067J, 2024, 93.859
Title: Southwest Forest Health and Wildfire Prevention
Funding Agency: United States Department of Agriculture
Federal Award Agreement Number:21-DG-11030000-020, 22-DG-11030000-013, 23-DG-11030000-014
Award Year:2024
Assistance Listing Number:10.694
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number:N/A
Award Year:2024
Assistance Listing Number:93.658
Pass-Through Agency:CYFD
Pass-Through Identification Number:23-690-500-25581
Condition: In testing 25 payroll items from each program listed above, CRI noted exceptions as
described in the following table. No exceptions were noted in the items tested for the Foster Care
program.
(See table in report pg 120)
Questioned Costs: Known and likely questioned costs of $4,547 and $506,209 are associated with the R&D Cluster related to discrepancies in time and effort documentation. No questioned costs were noted in the Southwest Forest Health and Wildfire Prevention Program or the Foster Care program.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Per 2 CFR section 200.403 – Factors affecting allowability of costs – Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: paragraph (a) Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles; paragraph (g) Be adequately documented.
Per 2 CFR section 200.430 – Compensation – personal services, paragraph (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Cause: The University does not have sufficient controls in place to ensure the accuracy of the amounts paid to employees nor include appropriate approvals documented to be allowable to be charged to the federal grant. The University has deficiencies recording and processing payroll as described in finding 2024-001.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.
2024-006 Activities Allowed and Allowable Costs (Significant Deficiency in Internal Controls over Compliance)
Title: Foster Care-Title IV-E
Funding Agency: United States Department of Health and Human Services
Federal Award Agreement Number: Not Applicable
Award Year: 2024
Assistance Listing Number: 93.658
Questioned Costs: Not Applicable
Condition: Three out of fifteen applications for stipend payments tested did not have final approval.
Questioned Costs: None noted.
Criteria: Per Title 2 US Code of Federal Regulations Part 200.303a, the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Cause: The University did not have sufficient controls in place to review application to ensure final approval.
Effect: The University may unintentionally charge expenses to the program that do not qualify and in turn lead to questioned costs and/or repayment of funds to the Grantor agency.