Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Equipment Property Management
Federal Program: Congressional Directives (ALN 93.493)
Federal Agency: Department of Health and Human Services
Federal Award Number: 1CE1HS52890-01-00
Federal Award Year: September 30, 2023 through June 30, 2024
Criteria or Requirement
Per 2 CFR section 200.313, property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the federal
award identification number), who holds title, the acquisition date, cost of the property, percentage of federal
participation in the project costs for the federal award under which the property was acquired, the location,
use and condition of the property, and any ultimate disposition data including the date of disposal and sales
price of the property.
Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 4 out of 14 purchase transactions or 17 out of 20 individual assets, equipment exceeding the capitalization
threshold per 2 CFR section 200.1 was not capitalized. Therefore, a property record did not exist for federally
funded equipment purchased in the amount of $1,758,365. The total program expenditures were $3,652,263
for which $2,776,884 were capital equipment purchases and $875,379 were non-capital purchases. For the
equipment that was capitalized and a property record was established, the property record did not properly
identify the asset as federally funded.
Cause and Potential Effect
The University's internal controls for determining and documenting whether an equipment acquisition was a
capital asset for which a property record should be created in the system with the required was not operating
effectively. Accordingly, the University acquired federally funded equipment and a property record was not
created.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over equipment purchases to ensure
that a property record is created within the system containing the required information for all federally funded
equipment.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the remedial
actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Period of Performance
Federal Program: Research and Development Cluster - Arthritis, Musculoskeletal and Skin Diseases
Research (ALN 93.846)
Federal Agency: Department of Health and Human Services
Federal Award Number: R01AR071410
Federal Award Year: July 1, 2023 through June 30, 2024
Criteria or Requirement
Per 2 CFR section 200.403(h), a non-federal entity may charge only allowable costs incurred during the
approved budget period of a federal award’s period of performance and any costs incurred before the
federal awarding agency or pass-through entity made the federal award that were authorized by the federal
awarding agency or pass-through entity.
Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 1 of 40 transactions sampled for period of performance, purchase incurred after the period of
performance was charged to the grant which is not allowable under the grant award or cost principles.
Cause and Potential Effect
The University's internal controls for determining a purchase is within the federal award’s period of
performance was not operating effectively. Accordingly, the University has requested reimbursement for
purchases incurred after the period of performance of the federal award.
Questioned Cost
There are known questioned costs of $16,017. The aggregated total sample for the 40 period of
performance transactions was $2,132,385. The total population for research and development cluster
expenditures aggregated $184,508,852.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over purchases to ensure the
purchases are incurred within the federal award’s period of performance and if incurred subsequent to the
federal award’s period of performance, are not charged to the federal agency.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Equipment Property Management
Federal Program: Congressional Directives (ALN 93.493)
Federal Agency: Department of Health and Human Services
Federal Award Number: 1CE1HS52890-01-00
Federal Award Year: September 30, 2023 through June 30, 2024
Criteria or Requirement
Per 2 CFR section 200.313, property records must be maintained that include a description of the property,
a serial number or other identification number, the source of funding for the property (including the federal
award identification number), who holds title, the acquisition date, cost of the property, percentage of federal
participation in the project costs for the federal award under which the property was acquired, the location,
use and condition of the property, and any ultimate disposition data including the date of disposal and sales
price of the property.
Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award
in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 4 out of 14 purchase transactions or 17 out of 20 individual assets, equipment exceeding the capitalization
threshold per 2 CFR section 200.1 was not capitalized. Therefore, a property record did not exist for federally
funded equipment purchased in the amount of $1,758,365. The total program expenditures were $3,652,263
for which $2,776,884 were capital equipment purchases and $875,379 were non-capital purchases. For the
equipment that was capitalized and a property record was established, the property record did not properly
identify the asset as federally funded.
Cause and Potential Effect
The University's internal controls for determining and documenting whether an equipment acquisition was a
capital asset for which a property record should be created in the system with the required was not operating
effectively. Accordingly, the University acquired federally funded equipment and a property record was not
created.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over equipment purchases to ensure
that a property record is created within the system containing the required information for all federally funded
equipment.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the remedial
actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Period of Performance
Federal Program: Research and Development Cluster - Arthritis, Musculoskeletal and Skin Diseases
Research (ALN 93.846)
Federal Agency: Department of Health and Human Services
Federal Award Number: R01AR071410
Federal Award Year: July 1, 2023 through June 30, 2024
Criteria or Requirement
Per 2 CFR section 200.403(h), a non-federal entity may charge only allowable costs incurred during the
approved budget period of a federal award’s period of performance and any costs incurred before the
federal awarding agency or pass-through entity made the federal award that were authorized by the federal
awarding agency or pass-through entity.
Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 1 of 40 transactions sampled for period of performance, purchase incurred after the period of
performance was charged to the grant which is not allowable under the grant award or cost principles.
Cause and Potential Effect
The University's internal controls for determining a purchase is within the federal award’s period of
performance was not operating effectively. Accordingly, the University has requested reimbursement for
purchases incurred after the period of performance of the federal award.
Questioned Cost
There are known questioned costs of $16,017. The aggregated total sample for the 40 period of
performance transactions was $2,132,385. The total population for research and development cluster
expenditures aggregated $184,508,852.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over purchases to ensure the
purchases are incurred within the federal award’s period of performance and if incurred subsequent to the
federal award’s period of performance, are not charged to the federal agency.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.
Finding No. 2024-002
Procurement – Suspension and Debarment
Federal Program, Federal Agency, Federal Award Number, Federal Award Year
Federal program ALN Federal Agency Federal Award Number Federal Award Year
R&D cluster 93.211 Department of Health and Human Services 2U66RH31458-04-00 July 1, 2023 to June 30, 2024
R&D cluster 93.243 Department of Health and Human Services 1H79SM085079-01 July 1, 2023 to June 30, 2024
R&D cluster 93.279 Department of Health and Human Services 5126934/1R01DA055523-01A1; U10DA013727-21 July 1, 2023 to June 30, 2024
R&D cluster 93.310 Department of Health and Human Services 1UG3OD035543-01,02 July 1, 2023 to June 30, 2024
R&D cluster 93.353 Department of Health and Human Services 3U01CA232491-02S1 July 1, 2023 to June 30, 2024
R&D cluster 93.395 Department of Health and Human Services 2R01CA181664-07A1 July 1, 2023 to June 30, 2024
R&D cluster 93.399 Department of Health and Human Services 5UG1CA189848-08; 7R01CA232888-05 July 1, 2023 to June 30, 2024
R&D cluster 93.847 Department of Health and Human Services 5U01DK104833-06 July 1, 2023 to June 30, 2024
R&D cluster 93.853 Department of Health and Human Services 1OT2NS129366-01 July 1, 2023 to June 30, 2024
Congressional Directives 93.493 Department of Health and Human Services CE1H552890 September 30, 2023 to June 30, 2024
Criteria or Requirement
Per 2 CFR section 180.300, when a non-federal entity enters into a covered transaction with an entity at a
lower tier, the non-federal entity must verify that the entity is not suspended or debarred or otherwise
excluded from participating in the transaction.Per 2 CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal
award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition and Context
For 11 out of 40 R&D procurement transactions and 9 out of 13 Congressional Directive procurement
transactions, the University could not provide documentation to support that they checked suspension and
debarment on a timely basis. The documentation provided evidenced that the University checked that the
vendor was not suspended or debarred at some point after the covered transaction occurred.
Cause and Potential Effect
The University’s internal controls for determining and documenting whether a vendor was not suspended or
debarred prior to entering into the covered procurement transaction with that vendor was not operating
effectively. Accordingly, the University could have entered into a covered procurement transaction with a
suspended or debarred vendor.
Questioned Cost
There were no questioned costs associated with the finding.
Statistically Valid Sample
The sample was not intended to be, and was not, a statistically valid sample.
Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit
No.
Recommendation
We recommend the University enhance the precision of the controls over suspension and debarment to
ensure that, prior to entering into each covered procurement transaction, the University has checked to
determine that the vendor is not suspended or debarred, and the results are documented.
View of Responsible Officials
Management of the University takes no exception to this reported finding. We have implemented the
remedial actions as outlined in our Corrective Action Plan.