2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 002 – Notification prior to disbursement of Title IV funds
Grantor: Department of Education
Cluster: Student Financial Assistance Cluster
Award Names: Federal Pell Grant Program
Award Numbers: Not applicable
Assistance Listing Titles: Federal Pell Grant Program
Assistance Listing Number: 84.063
Award Year: 2023-2024
Passthrough Entity: Not applicable
Criteria:
Per 34 CFR 668.165(a) before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award
year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If funds include a Direct Loan, the notice must indicate which funds are subsidized loans and which are unsubsidized loans.
Condition:
For one of 25 samples selected for testing, the award letter notification to the student was not sent prior to disbursing funds. In this instance the student was awarded a Pell grant, and the award letter notification was made after the disbursement of the grant funds. The notification to the student was dated 12/7/2023 and the disbursement date was 8/31/2023.
Cause:
In this instance, the student’s financial aid was packaged manually, and the award letter notification code was not entered by the individual responsible for packaging the aid which resulted in not triggering notification to the student prior to disbursement.
Effect:
The student was not notified of the amount of the Pell grant award and when and how the funds would be disbursed in advance of disbursing the funds.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
We recommend the University enhance controls when packaging aid to ensure an award letter code is assigned so that
notification is sent to students prior to disbursing financial aid.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 002 – Notification prior to disbursement of Title IV funds
Grantor: Department of Education
Cluster: Student Financial Assistance Cluster
Award Names: Federal Pell Grant Program
Award Numbers: Not applicable
Assistance Listing Titles: Federal Pell Grant Program
Assistance Listing Number: 84.063
Award Year: 2023-2024
Passthrough Entity: Not applicable
Criteria:
Per 34 CFR 668.165(a) before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award
year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If funds include a Direct Loan, the notice must indicate which funds are subsidized loans and which are unsubsidized loans.
Condition:
For one of 25 samples selected for testing, the award letter notification to the student was not sent prior to disbursing funds. In this instance the student was awarded a Pell grant, and the award letter notification was made after the disbursement of the grant funds. The notification to the student was dated 12/7/2023 and the disbursement date was 8/31/2023.
Cause:
In this instance, the student’s financial aid was packaged manually, and the award letter notification code was not entered by the individual responsible for packaging the aid which resulted in not triggering notification to the student prior to disbursement.
Effect:
The student was not notified of the amount of the Pell grant award and when and how the funds would be disbursed in advance of disbursing the funds.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
We recommend the University enhance controls when packaging aid to ensure an award letter code is assigned so that
notification is sent to students prior to disbursing financial aid.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 003 – Reporting
Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP)
Program Name: Disability Employment Policy Development
Award Names: Disability Employment Policy Development
Award Numbers: 3475OD000001-01-00 (passthrough ID 24-SA-053-3203)
Assistance Listing Titles: Disability Employment Policy Development
Assistance Listing Number: 17.720
Award Year: 2024
Passthrough Entity: The Council of State Governments
Criteria:
2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal award. Intervals must be no less frequent than annually nor more frequent than quarterly except if specific conditions are applied. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Per the award agreement, quarterly performance reports are required to be submitted within 30 calendar days after the end of each calendar-year quarter.
Condition:
For the two quarterly performance reports tested, the reports were submitted after 30 days; (1) the performance report for the period of October 1, 2023 through December 31, 2023 was submitted on February 14, 2024, after the due date of January 30, 2024 and (2) the performance report for the period January 1, 2024 to March 31, 2024 was submitted on May 15, 2024, after the due date of April 30, 2024.
Cause:
The University was following the DOL funding application document which included the requirement to submit quarterly
performance reports within 45 days after the end of each calendar-year quarter and not the award agreement which states that the quarterly performance reports must be submitted within 30 days after the end of each calendar-year quarter.
Effect:
The University did not submit the quarterly performance reports within the required time period per the award agreement, consequently, was not in compliance with the performance reporting requirement.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
The University should ensure timely submission of reports is performed as stated within the award agreement.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 003 – Reporting
Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP)
Program Name: Disability Employment Policy Development
Award Names: Disability Employment Policy Development
Award Numbers: 3475OD000001-01-00 (passthrough ID 24-SA-053-3203)
Assistance Listing Titles: Disability Employment Policy Development
Assistance Listing Number: 17.720
Award Year: 2024
Passthrough Entity: The Council of State Governments
Criteria:
2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal award. Intervals must be no less frequent than annually nor more frequent than quarterly except if specific conditions are applied. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Per the award agreement, quarterly performance reports are required to be submitted within 30 calendar days after the end of each calendar-year quarter.
Condition:
For the two quarterly performance reports tested, the reports were submitted after 30 days; (1) the performance report for the period of October 1, 2023 through December 31, 2023 was submitted on February 14, 2024, after the due date of January 30, 2024 and (2) the performance report for the period January 1, 2024 to March 31, 2024 was submitted on May 15, 2024, after the due date of April 30, 2024.
Cause:
The University was following the DOL funding application document which included the requirement to submit quarterly
performance reports within 45 days after the end of each calendar-year quarter and not the award agreement which states that the quarterly performance reports must be submitted within 30 days after the end of each calendar-year quarter.
Effect:
The University did not submit the quarterly performance reports within the required time period per the award agreement, consequently, was not in compliance with the performance reporting requirement.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
The University should ensure timely submission of reports is performed as stated within the award agreement.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 001 – Allowable costs/cost principles - Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health
Cluster: Research and Development Cluster
Award Names: Various
Award Numbers: Various
Assistance Listing Titles: Cancer Research Manpower; Diabetes, Digestive, and Kidney Diseases Extramural Research; ACL
National Institute on Disability, Independent Living and Rehabilitation Research; Aging Research; Cardiovascular Diseases Research; Drug Abuse and Addiction Research Programs; Allergy and Infectious Diseases Research
Assistance Listing Number: 93.398, 93.847, 93.433, 93.866, 93.837, 93.279, 93.855
Award Year: 2023-2024
Passthrough Entity: Various
Criteria:
The Department of Health and Human Services Grants Policy Statement and the National Institute of Health Grants PolicyStatement requires cost transfers that represent corrections of clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days following the occurrence. Cost transfers must be appropriately justified, documented and completed in a timely manner to support its allowability. In addition, 2 CFR 200.334 requires recipients to maintain Federal Award records for three years from the date of submission of their quarterly or annual financial report.
Condition:
Of the 25 cost transfers selected for testing, we noted the following related to Weill Cornell Medicine cost transfers:
the journal voucher for three salary cost transfers did not include the justification explaining the reason for the cost transfer; the journal voucher for five salary cost transfers which were over 90 days did not include the justification explaining the reason for the cost transfer or the reason the cost transfer was over 90 days; and the cost transfer form for two non-salary cost transfer over 90 days did not include sufficient documentation explaining the reason the cost transfer was over 90 days.
Cause:
For the eight salary cost transfers noted, manual journal vouchers were used but did not include formal comprehensive
justification explaining the reason for the cost transfer and/or supporting documentation. Additionally, for the five salary cost transfers that were over 90 days, the journal voucher did not include the justification for the late cost transfer. The salary cost transfer justification, supporting details and approvals were maintained separately in email communications and not as part of a comprehensive record for the salary cost transfers. Upon termination, email communications of employees may not be retained, and in at least one instance tested, the email supporting documentation was not retained. The University did not require the supporting documentation and justification to be included with the journal voucher. For the non-salary cost transfer instances noted, the cost transfer form was completed but did not contain sufficient detail of the justification explaining the reason for the late transfer.
Effect:
The cost transfer journal voucher or cost transfer form, as applicable, did not maintain complete documentary evidence of the reason for the cost transfer and reason for a late transfer for the cost transfers beyond 90 days in accordance with federal guidelines.
Questioned Costs:
There were no questioned costs associated with this finding as the cost transfers were allowable and allocable to the awards to which they were transferred.
Recommendation:
We recommend the University review and update its cost transfer policies and procedures to require maintaining a
comprehensive record for all cost transfers including justification, supporting documentation, and sufficient justification for cost transfers over 90 days. Additionally, we recommend the University communicate, provide training and enforce policies and procedures to ensure cost transfers are executed and documented consistently in accordance with the University’s policy and procedures and federal guidelines.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 002 – Notification prior to disbursement of Title IV funds
Grantor: Department of Education
Cluster: Student Financial Assistance Cluster
Award Names: Federal Pell Grant Program
Award Numbers: Not applicable
Assistance Listing Titles: Federal Pell Grant Program
Assistance Listing Number: 84.063
Award Year: 2023-2024
Passthrough Entity: Not applicable
Criteria:
Per 34 CFR 668.165(a) before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award
year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If funds include a Direct Loan, the notice must indicate which funds are subsidized loans and which are unsubsidized loans.
Condition:
For one of 25 samples selected for testing, the award letter notification to the student was not sent prior to disbursing funds. In this instance the student was awarded a Pell grant, and the award letter notification was made after the disbursement of the grant funds. The notification to the student was dated 12/7/2023 and the disbursement date was 8/31/2023.
Cause:
In this instance, the student’s financial aid was packaged manually, and the award letter notification code was not entered by the individual responsible for packaging the aid which resulted in not triggering notification to the student prior to disbursement.
Effect:
The student was not notified of the amount of the Pell grant award and when and how the funds would be disbursed in advance of disbursing the funds.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
We recommend the University enhance controls when packaging aid to ensure an award letter code is assigned so that
notification is sent to students prior to disbursing financial aid.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 002 – Notification prior to disbursement of Title IV funds
Grantor: Department of Education
Cluster: Student Financial Assistance Cluster
Award Names: Federal Pell Grant Program
Award Numbers: Not applicable
Assistance Listing Titles: Federal Pell Grant Program
Assistance Listing Number: 84.063
Award Year: 2023-2024
Passthrough Entity: Not applicable
Criteria:
Per 34 CFR 668.165(a) before an institution disburses Title IV, Higher Education Act (HEA) program funds for any award
year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed. If funds include a Direct Loan, the notice must indicate which funds are subsidized loans and which are unsubsidized loans.
Condition:
For one of 25 samples selected for testing, the award letter notification to the student was not sent prior to disbursing funds. In this instance the student was awarded a Pell grant, and the award letter notification was made after the disbursement of the grant funds. The notification to the student was dated 12/7/2023 and the disbursement date was 8/31/2023.
Cause:
In this instance, the student’s financial aid was packaged manually, and the award letter notification code was not entered by the individual responsible for packaging the aid which resulted in not triggering notification to the student prior to disbursement.
Effect:
The student was not notified of the amount of the Pell grant award and when and how the funds would be disbursed in advance of disbursing the funds.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
We recommend the University enhance controls when packaging aid to ensure an award letter code is assigned so that
notification is sent to students prior to disbursing financial aid.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 003 – Reporting
Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP)
Program Name: Disability Employment Policy Development
Award Names: Disability Employment Policy Development
Award Numbers: 3475OD000001-01-00 (passthrough ID 24-SA-053-3203)
Assistance Listing Titles: Disability Employment Policy Development
Assistance Listing Number: 17.720
Award Year: 2024
Passthrough Entity: The Council of State Governments
Criteria:
2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal award. Intervals must be no less frequent than annually nor more frequent than quarterly except if specific conditions are applied. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Per the award agreement, quarterly performance reports are required to be submitted within 30 calendar days after the end of each calendar-year quarter.
Condition:
For the two quarterly performance reports tested, the reports were submitted after 30 days; (1) the performance report for the period of October 1, 2023 through December 31, 2023 was submitted on February 14, 2024, after the due date of January 30, 2024 and (2) the performance report for the period January 1, 2024 to March 31, 2024 was submitted on May 15, 2024, after the due date of April 30, 2024.
Cause:
The University was following the DOL funding application document which included the requirement to submit quarterly
performance reports within 45 days after the end of each calendar-year quarter and not the award agreement which states that the quarterly performance reports must be submitted within 30 days after the end of each calendar-year quarter.
Effect:
The University did not submit the quarterly performance reports within the required time period per the award agreement, consequently, was not in compliance with the performance reporting requirement.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
The University should ensure timely submission of reports is performed as stated within the award agreement.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.
2024 – 003 – Reporting
Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP)
Program Name: Disability Employment Policy Development
Award Names: Disability Employment Policy Development
Award Numbers: 3475OD000001-01-00 (passthrough ID 24-SA-053-3203)
Assistance Listing Titles: Disability Employment Policy Development
Assistance Listing Number: 17.720
Award Year: 2024
Passthrough Entity: The Council of State Governments
Criteria:
2 CFR 200.329 requires non-Federal entities to submit performance reports as required by the Federal award. Intervals must be no less frequent than annually nor more frequent than quarterly except if specific conditions are applied. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Per the award agreement, quarterly performance reports are required to be submitted within 30 calendar days after the end of each calendar-year quarter.
Condition:
For the two quarterly performance reports tested, the reports were submitted after 30 days; (1) the performance report for the period of October 1, 2023 through December 31, 2023 was submitted on February 14, 2024, after the due date of January 30, 2024 and (2) the performance report for the period January 1, 2024 to March 31, 2024 was submitted on May 15, 2024, after the due date of April 30, 2024.
Cause:
The University was following the DOL funding application document which included the requirement to submit quarterly
performance reports within 45 days after the end of each calendar-year quarter and not the award agreement which states that the quarterly performance reports must be submitted within 30 days after the end of each calendar-year quarter.
Effect:
The University did not submit the quarterly performance reports within the required time period per the award agreement, consequently, was not in compliance with the performance reporting requirement.
Questioned Costs:
There were no questioned costs associated with this finding.
Recommendation:
The University should ensure timely submission of reports is performed as stated within the award agreement.
Management’s Views and Corrective Action Plan:
Please refer to the University’s Management’s Views and Corrective Action Plan included at the end of this report for
additional details.