Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑002 Research and Development Cluster:
Department of Health and Human Servies – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286) Department of Education:
Pass-through from University of Massachusetts Boston:
Research and Innovation to Improve Services and Results for Children with Disability (ALN 84.324A) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Presentation of Schedule of Expenditures of Federal Awards – Significant Deficiency. Criteria: As defined in 2 CFR section 200.1, Research and Development, “research” is a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. R&D means all research activities, both basic and applied, and all development activities performed by non-federal entities. The term “research” also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other R&D activities and when such activities are not included in the instruction function. The non-federal entity is required to cluster these grants into one federal program. As defined by Uniform Guidance (2 CFR 200), entities are required to present subrecipient expenses on the Schedule of Expenditures of Federal Awards (SEFA). Further, the non Federal entity must establish and maintain effective internal controls over the preparation of the SEFA that provides reasonable assurance that the non Federal entity is properly presenting Federal awards on the SEFA in accordance with the Uniform Guidance. Condition and Context: During the test work over the SEFA, we selected a sample of grant agreements to determine that the grants were properly presented on the SEFA. We identified two grants in the amount $45,021 that were not included in the Research of Development Cluster (RD). Once included, the total RD expenditures exceeded $750,000 and required RD to be audited as a major program. Additionally, through our test work over RD, there were subrecipient expenditures in the amount of $24,379 that were not disclosed on the SEFA. Cause: For one grant, management did not identify within the grant agreement that it was indicated to be an RD grant. For another grant it was included in the RD cluster, but not properly included in the RD total on the SEFA. The subrecipient expenditures related to a grant where the Principal Investigator (PI) left the University in the middle of fiscal year 2024. The PI did not properly code the expenses to a subrecipient expenditure general ledger code prior to leaving. Effect: If grants are not properly identified as part of RD, then the program may not be properly classified as Type A or Type B program, which may cause an inappropriate risk assessment to be performed. In addition, if expenditures are not classified in the appropriate expenditure category, then the population of expenditures subject to audit may not be complete and accurate, resulting in certain suggested audit procedures not being performed. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over the presentation of the SEFA. Management should review the SEFA, along with all the grant agreements to ensure that all elements of the SEFA are accurately included and all expenditures and cluster are complete. Views of Responsible Official: Management agrees with the recommendation. The University will implement an additional level of review within the Finance Department over the Schedule of Expenditures of Federal Awards in order to ensure accuracy and completeness of the schedule. In addition, there will be inclusion of the Office of Grants and Sponsored Projects in the preparation and review of the schedule. The University is also looking into the implementation of software for award management to help avoid future oversights.
Finding No. 2024‑002 Research and Development Cluster:
Department of Health and Human Servies – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286) Department of Education:
Pass-through from University of Massachusetts Boston:
Research and Innovation to Improve Services and Results for Children with Disability (ALN 84.324A) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Presentation of Schedule of Expenditures of Federal Awards – Significant Deficiency. Criteria: As defined in 2 CFR section 200.1, Research and Development, “research” is a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. R&D means all research activities, both basic and applied, and all development activities performed by non-federal entities. The term “research” also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other R&D activities and when such activities are not included in the instruction function. The non-federal entity is required to cluster these grants into one federal program. As defined by Uniform Guidance (2 CFR 200), entities are required to present subrecipient expenses on the Schedule of Expenditures of Federal Awards (SEFA). Further, the non Federal entity must establish and maintain effective internal controls over the preparation of the SEFA that provides reasonable assurance that the non Federal entity is properly presenting Federal awards on the SEFA in accordance with the Uniform Guidance. Condition and Context: During the test work over the SEFA, we selected a sample of grant agreements to determine that the grants were properly presented on the SEFA. We identified two grants in the amount $45,021 that were not included in the Research of Development Cluster (RD). Once included, the total RD expenditures exceeded $750,000 and required RD to be audited as a major program. Additionally, through our test work over RD, there were subrecipient expenditures in the amount of $24,379 that were not disclosed on the SEFA. Cause: For one grant, management did not identify within the grant agreement that it was indicated to be an RD grant. For another grant it was included in the RD cluster, but not properly included in the RD total on the SEFA. The subrecipient expenditures related to a grant where the Principal Investigator (PI) left the University in the middle of fiscal year 2024. The PI did not properly code the expenses to a subrecipient expenditure general ledger code prior to leaving. Effect: If grants are not properly identified as part of RD, then the program may not be properly classified as Type A or Type B program, which may cause an inappropriate risk assessment to be performed. In addition, if expenditures are not classified in the appropriate expenditure category, then the population of expenditures subject to audit may not be complete and accurate, resulting in certain suggested audit procedures not being performed. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over the presentation of the SEFA. Management should review the SEFA, along with all the grant agreements to ensure that all elements of the SEFA are accurately included and all expenditures and cluster are complete. Views of Responsible Official: Management agrees with the recommendation. The University will implement an additional level of review within the Finance Department over the Schedule of Expenditures of Federal Awards in order to ensure accuracy and completeness of the schedule. In addition, there will be inclusion of the Office of Grants and Sponsored Projects in the preparation and review of the schedule. The University is also looking into the implementation of software for award management to help avoid future oversights.
Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑001 Research and Development Cluster:
National Science Foundation:
Hispanic-Serving Institutions Pilot Project STEM Undergraduate, Retention, Graduation and Engagement (ALN 47.076)
U.S. Department of Health and Human Services – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286)
Plasma-Initiated Cross-Linked Nanocoatings as Anti-Infection Agents (ALN 93.855) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Equipment and Real Property Management – Material Weakness and Material Noncompliance Criteria Non-federal entities other than states must follow 2 CFR sections 200.313(c) through (e) which require that: 1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). 2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). 3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition and Context. There were several matters noted. First, there was no evidence that the University conducted a physical inventory of its federal equipment in the past two years. The value of equipment related to the Research and Development Cluster is $278,787 at June 30, 2024. Second, we selected 7 pieces of equipment out of 65 pieces of equipment that existed at June 30, 2024, and while they were all properly tagged, we noted during our understanding of the process and controls over the process that the tagging of equipment was not done timely as all equipment acquired in a fiscal year is tagged the following August. Third, we selected 3 pieces of equipment out of 14 pieces of equipment that were acquired in fiscal year 2024. While the property records included all of the required elements, there was no evidence of review that current year acquisitions of equipment are accurately included in the University's equipment subledger, and this equipment was not reconciled to a physical inventory, as an inventory did not take place. Cause: Management was not aware of all the compliance requirements over federally purchased equipment, including that a physical inventory must be performed at least once every two years. Additionally, the University has limited resources and this impacts the timing of the tagging of equipment and the review of equipment records. Effect: The equipment purchased with federal funds may not be properly safeguarded. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over equipment, including adding procedures to perform the physical inventory at least once every two years, timely tagging equipment upon the purchase of equipment with federal funds, and properly reviewing and reconciling equipment records with the results of the inventory. Views of Responsible Official: Management agrees with the recommendation. Prior to June 30, 2025, the University will conduct a full physical inventory of equipment purchased using federal funds that have a net book value greater than zero on the University’s books as of June 30, 2024. For new purchases of equipment using federal funds, the University will tag these assets on a monthly basis. In addition, a physical inventory of equipment purchased using federal funds will be conducted every two years going forward. The inventory process will be reviewed by management to ensure timely and accurate completion.
Finding No. 2024‑002 Research and Development Cluster:
Department of Health and Human Servies – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286) Department of Education:
Pass-through from University of Massachusetts Boston:
Research and Innovation to Improve Services and Results for Children with Disability (ALN 84.324A) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Presentation of Schedule of Expenditures of Federal Awards – Significant Deficiency. Criteria: As defined in 2 CFR section 200.1, Research and Development, “research” is a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. R&D means all research activities, both basic and applied, and all development activities performed by non-federal entities. The term “research” also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other R&D activities and when such activities are not included in the instruction function. The non-federal entity is required to cluster these grants into one federal program. As defined by Uniform Guidance (2 CFR 200), entities are required to present subrecipient expenses on the Schedule of Expenditures of Federal Awards (SEFA). Further, the non Federal entity must establish and maintain effective internal controls over the preparation of the SEFA that provides reasonable assurance that the non Federal entity is properly presenting Federal awards on the SEFA in accordance with the Uniform Guidance. Condition and Context: During the test work over the SEFA, we selected a sample of grant agreements to determine that the grants were properly presented on the SEFA. We identified two grants in the amount $45,021 that were not included in the Research of Development Cluster (RD). Once included, the total RD expenditures exceeded $750,000 and required RD to be audited as a major program. Additionally, through our test work over RD, there were subrecipient expenditures in the amount of $24,379 that were not disclosed on the SEFA. Cause: For one grant, management did not identify within the grant agreement that it was indicated to be an RD grant. For another grant it was included in the RD cluster, but not properly included in the RD total on the SEFA. The subrecipient expenditures related to a grant where the Principal Investigator (PI) left the University in the middle of fiscal year 2024. The PI did not properly code the expenses to a subrecipient expenditure general ledger code prior to leaving. Effect: If grants are not properly identified as part of RD, then the program may not be properly classified as Type A or Type B program, which may cause an inappropriate risk assessment to be performed. In addition, if expenditures are not classified in the appropriate expenditure category, then the population of expenditures subject to audit may not be complete and accurate, resulting in certain suggested audit procedures not being performed. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over the presentation of the SEFA. Management should review the SEFA, along with all the grant agreements to ensure that all elements of the SEFA are accurately included and all expenditures and cluster are complete. Views of Responsible Official: Management agrees with the recommendation. The University will implement an additional level of review within the Finance Department over the Schedule of Expenditures of Federal Awards in order to ensure accuracy and completeness of the schedule. In addition, there will be inclusion of the Office of Grants and Sponsored Projects in the preparation and review of the schedule. The University is also looking into the implementation of software for award management to help avoid future oversights.
Finding No. 2024‑002 Research and Development Cluster:
Department of Health and Human Servies – National Institutes of Health:
Antibiotic-Free Anti-Infection Polymer Brush Biocoatings (ALN 93.286) Department of Education:
Pass-through from University of Massachusetts Boston:
Research and Innovation to Improve Services and Results for Children with Disability (ALN 84.324A) Statistically valid sample: No and it was not intended to be. Repeat finding: Not a repeat finding. Compliance Requirement – Presentation of Schedule of Expenditures of Federal Awards – Significant Deficiency. Criteria: As defined in 2 CFR section 200.1, Research and Development, “research” is a systematic study directed toward fuller scientific knowledge or understanding of the subject studied. “Development” is the systematic use of knowledge and understanding gained from research directed toward the production of useful materials, devices, systems, or methods, including design and development of prototypes and processes. R&D means all research activities, both basic and applied, and all development activities performed by non-federal entities. The term “research” also includes activities involving the training of individuals in research techniques where such activities utilize the same facilities as other R&D activities and when such activities are not included in the instruction function. The non-federal entity is required to cluster these grants into one federal program. As defined by Uniform Guidance (2 CFR 200), entities are required to present subrecipient expenses on the Schedule of Expenditures of Federal Awards (SEFA). Further, the non Federal entity must establish and maintain effective internal controls over the preparation of the SEFA that provides reasonable assurance that the non Federal entity is properly presenting Federal awards on the SEFA in accordance with the Uniform Guidance. Condition and Context: During the test work over the SEFA, we selected a sample of grant agreements to determine that the grants were properly presented on the SEFA. We identified two grants in the amount $45,021 that were not included in the Research of Development Cluster (RD). Once included, the total RD expenditures exceeded $750,000 and required RD to be audited as a major program. Additionally, through our test work over RD, there were subrecipient expenditures in the amount of $24,379 that were not disclosed on the SEFA. Cause: For one grant, management did not identify within the grant agreement that it was indicated to be an RD grant. For another grant it was included in the RD cluster, but not properly included in the RD total on the SEFA. The subrecipient expenditures related to a grant where the Principal Investigator (PI) left the University in the middle of fiscal year 2024. The PI did not properly code the expenses to a subrecipient expenditure general ledger code prior to leaving. Effect: If grants are not properly identified as part of RD, then the program may not be properly classified as Type A or Type B program, which may cause an inappropriate risk assessment to be performed. In addition, if expenditures are not classified in the appropriate expenditure category, then the population of expenditures subject to audit may not be complete and accurate, resulting in certain suggested audit procedures not being performed. Questioned Costs: There were no questioned costs related to this finding. Recommendation: We recommend that the University strengthen its policies and procedures over the presentation of the SEFA. Management should review the SEFA, along with all the grant agreements to ensure that all elements of the SEFA are accurately included and all expenditures and cluster are complete. Views of Responsible Official: Management agrees with the recommendation. The University will implement an additional level of review within the Finance Department over the Schedule of Expenditures of Federal Awards in order to ensure accuracy and completeness of the schedule. In addition, there will be inclusion of the Office of Grants and Sponsored Projects in the preparation and review of the schedule. The University is also looking into the implementation of software for award management to help avoid future oversights.